John Lothian Newsletter: Sommers Will Leave CFTC July 8 After Leading Review of MF Global; Europe steps up regulatory assault on CDS; Deutsche Börse launches cloud computing marketplace

Jul 2, 2013

CFTC commissioner Jill Sommers will head out the front door next week, vacating her position there. The EU turns up the heat on derivatives traders, and considers past sins as well as future requirements. Deutsche Börse announces plans to create a trading venue for cloud computing resources.

First Read

The Pressure’s On
Pat KennyCQG

I don’t edit newsletters often, but when I do I do it for the John Lothian Newsletter. Keep reading, my friends….

It’s not easy being on a pedestal, particularly after being labeled “the most interesting man in the world.” With as much pressure as such a title puts on me, it’s even harder to be the guest editor this week of the JLN newsletter. Even the trading pits were less stressful.

I do live an exciting life because of the extensive traveling I do and the opportunities that such travels present. When in London last week, I was invited by my friends at FFastfill to participate in the annual cricket match for the Futures for Kids charity event. I was the only U.S. player on either team; the pressure was on to represent. With the help from my teammates, team Barbarian captured their first win over team England. The cricket match was followed by a gala event at which I was not the only one wearing a tux this time. (A stark contrast to the days of playing hockey at the local ice arena and then heading to Johnny’s for a beer.)

Life is never boring in the futures world; who knows what tomorrow will bring?


CME Group Volume Averaged 16.9 Million Contracts per Day in June 2013, Up 29 Percent from June 2012
CME Group, the world’s leading and most diverse derivatives marketplace, today announced that June 2013 volume averaged 16.9 million contracts per day, up 29 percent compared with June 2012, and up 15 percent sequentially. Total volume for June 2013 was more than 339 million contracts, of which 86 percent was traded electronically.

***JK: Stay tuned for a JLN Q&A with Phupinder Gill, William Knottenbelt and Lee Betsill from CME.

***PK: Congrats to my friends at CME, I’m happy to still have my CME membership


CBOE Holdings Records Highest Volume For Any Month In 2013 During June
CBOE Holdings, Inc. reported today that June trading volume for options contracts on Chicago Board Options Exchange and C2 Options Exchange and futures contracts on CBOE Futures Exchange totaled 107.52 million contracts, the highest monthly volume to date in 2013. Average daily volume in June was 5.38 million contracts, up 14 percent from 4.71 million contracts in June 2012 and up 10 percent from 4.87 million contracts in May 2013.

***JK: Options volumes were up 7 percent from a year earlier in June and total volume, options and future rose 9 percent..


OneChicago’s Second Quarter 2013 Trading Volume Increases 80% as compared with 2012
OneChicago, LLC, an equity finance exchange, today announced volume of 780,133 June 2013.


NYSE Liffe U.S. Announces New Records For Mini MSCI Futures
Continuing the record-setting pace established in 2012 and carried into 2013, the mini MSCI futures complex had its first-ever month of over 1 million contracts traded with a total of 1.3 million in June.

***JK: A Most Satisfying Capital Index.


CME Group Announces First Trade of New USD-Denominated Palm Oil Swaps
CME Group, the world’s leading and most diverse derivatives marketplace, today announced the first USD Malaysian Crude Palm Oil Calendar Swaps were cleared on 21 June 2013, through CME ClearPort. The trade was between Gunvor Group and Louis Dreyfus Commodities, and was brokered by Starsupply (SG) Pte Ltd, part of the SCB Group.

***JK: For softer skin, trade USD-Denominated Palm Oil Swaps.


Innovation and Change in a Regulatory Fishbowl
Larry Tabb – TABB Forum
Faced with intensifying regulatory burdens and a challenging business environment, capital markets firms may find it difficult to drive meaningful change. But now is precisely the time firms need to innovate most.


SGX branches out into FX derivatives
Jonathan Watkins – Future and Options Intelligence
The Singapore Exchange (SGX) is hoping to maintain the momentum of its derivatives volume growth by breaking into the foreign exchange market. It is the latest in a string of expansion moves by the Asian bourse as it responds to mounting competition in the Asian derivatives market, one of the most lucrative regions in the world.


Quantopian Wants To Turn Stock Trading Algorithmic
Financial theory argues that over the long-run, individuals can’t beat the market. But a Boston start-up, Quantopian — its service lets people build, test, and execute trading algorithms — has developed software for those who want to try.


Emerging Markets Hit by Converging Forces
Countries from Turkey to Brazil to China are getting hit by a brutal combination of events, as economies slow, investors pull out cash, commodity prices tumble and protesters take to the streets—all fresh reminders that these markets can be difficult places to try to make money.


The Essential Wall St. Summer Reading List
If there is one question I am consistently asked every summer, it is this: What’s the best business book that I should be reading? It’s an oddly challenging question given the number of terrific books that have been written over the years about the world of business and finance. Invariably, I punt on the question and blurt out a couple of obvious classics.

***JK: A nice list of classics. There’s also Cinnober’s annual tradition of Swedish mystery novels, which turned us onto The Girl With the Dragon Tattoo books long before they became pop.


Rent Asunder: A Chicago Tribune Tale…
Rent Asunder is a complex tale, consisting of four sub-plots which ultimately intersect against a nearly exclusively Chicago backdrop — a Chicago Police Department superintendent and his deputies, ranking Chicago politicians, leaders of the Chicago Mercantile Exchange, the world’s preeminent derivatives market, and staff at the Chicago Tribune, a once dominant news outlet now teetering on bankruptcy.

***JM: …link provided by Andy Yemma. Now you REALLY have something to read this summer.



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Lead Stories

Sommers Will Leave CFTC July 8 After Leading Review of MF Global
Jill E. Sommers, the U.S. Commodity Futures Trading Commission member who oversaw the agency’s investigation into the collapse of MF Global Holdings Ltd., will step down from the agency next week.

Europe steps up regulatory assault on CDS
Alex Barker in Brussels, Philip Stafford in London and Tracy Alloway in New York –
Investment banks’ lucrative role as the middlemen of derivatives markets have long been under regulatory attack. But Brussels is not only rewriting rules for future trading and clearing; it could now punish banks for their past dominance.

Deutsche Börse launches marketplace for trading outsourced storage and computing capacity
Deutsche Börse today announced that it will launch a trading venue for outsourced storage and computing capacity – so called “cloud computing” resources – in the beginning of 2014: Deutsche Börse Cloud Exchange AG is a new joint venture formed together with Berlin-based Zimory GmbH to create the first neutral, secure and transparent trading venue for “cloud computing” resources.

The confessions of Andy Fastow
CNN Money
The convicted former Enron CFO is now admitting his sins to audiences — but also claiming that what other companies are doing today is “10 times worse” than what Enron did.

EU charges banks with blocking exchanges from derivatives market
Reuters via Yahoo! News
By Foo Yun Chee BRUSSELS – EU watchdogs have charged 13 top investment banks with blocking exchanges’ access to the lucrative credit derivatives market, hitting the sector with the latest in a growing list of regulatory headaches.

Europe’s Odd Antitrust Case Against the Banks
EU antitrust regulators announced that they had reached a “preliminary conclusion” that 13 of the largest banks had violated antitrust regulations by colluding to prevent exchanges from entering the derivatives business.

LME Seeks to Reduce Lines at Warehouses Where Wait Is 100 Days
The London Metal Exchange, the world’s biggest metals marketplace, is seeking to reduce waiting times to withdraw metal from warehouses where the lines are more than 100 calendar days.

New evidence emerges in Corzine case
CNN Money
Recorded phone conversations from MF Global are at the center of allegations from the Commodities Futures Trading Commission.

It’s time for a proper debate about the role of financial data
Ben Wright – Financial News
Who owns market data? Is it the buyers and sellers of a security or the venue at which they convene? This has been a controversial question for at least 150 years, ever since an American electrician by the name of Edward Calahan invented the stock ticker in 1863.


Timothy B. Henseler Named Director Of The SEC’s Office Of Legislative And Intergovernmental Affairs
The Securities and Exchange Commission today announced that Timothy B. Henseler has been named as Director of the agency’s Office of Legislative and Intergovernmental Affairs, effective immediately.

Chicago Regional Office Director Merri Jo Gillette To Leave SEC
The Securities and Exchange Commission today announced that Merri Jo Gillette, Director of its Chicago Regional Office, is leaving the agency later this month after more than 25 years of service.

SEC: Julie M. Riewe And Marshall S. Sprung Named Co-Chiefs Of Asset Management Unit
The Securities and Exchange Commission today announced that Julie M. Riewe and Marshall S. Sprung have been named Co-Chiefs of the Division of Enforcement’s Asset Management Unit, a national specialized unit that focuses on misconduct by investment advisers, investment companies, and private funds.

CFTC’s Division of Swap Dealer and Intermediary Oversight Provides Additional Time to Secure No-Action Relief by Persons Engaging in Floor Trader Activities, for Purposes of Making Calculations Under the Swap Dealer Definition
The Commodity Futures Trading Commission’s (CFTC) Division of Swap Dealer and Intermediary Oversight (DSIO) today announced that additional time would be provided to persons seeking to rely upon a recently-issued no-action letter.

FINRA Selects Morningstar for Re-Launch of Market Data Center
The Financial Industry Regulatory Authority (FINRA) announced today that it selected Morningstar, Inc. to provide financial data, technology and design for the re-launch of FINRA’s Market Data Center.

NFA Regulatory Requirements for FCMs, IBs, CPOs and CTAs
Updated to reflect the amendments to NFA Financial Requirements Section 16 and the related interpretive notice regarding cleared swaps customer collateral accounts.

UK’s Financial Conduct Authority Holds Key Conference On Financial Crime – Review Announced Into How UK Banks Control Money Laundering, Terrorist Financing And Sanctions Risks In Trade Finance
Opening the UK regulator’s Financial Crime Conference today, Martin Wheatley, Chief Executive of the Financial Conduct Authority (the FCA) today announced, “The FCA will do all it can to make Britain a hostile place for criminals to profit from their crimes.”

ESMA Review Finds Good Compliance With EU Market Abuse Rules
The European Securities and Markets Authority (ESMA) has published a peer review of the supervisory practices EEA national competent authorities (NCAs) apply in enforcing the requirements of the Market Abuse Directive (MAD). The Directive deals with the prevention of the dissemination of misleading information, the breach of reporting obligations and market abuse.

[ASIC] Focuses for 30 June 2013 financial reports

[France] AMF Scientific Advisory Board conference organised in partnership with the IFA Research Club: “Functioning of the board of directors, compensation and transparency: how should companies be governed?”

[Japan] FSA publishes Weekly Review No.52

Exchanges & Trading Facilities

June 2013 Is Busiest Month On Record For VIX Futures Trading At CFE
The CBOE Futures Exchange, LLC announced today that June 2013 was the most-active trading month for futures on the CBOE Volatility Index in exchange history. New records for total trading volume and average daily volume were set during the month and for the second quarter of the year.

The Options Industry Council Announces June Options Volume Up 11 Percent
The Options Industry Council (OIC) announced today that 361,180,257 total options contracts traded in June, which is up 10.86 percent compared to last year when 325,813,094 contracts were traded.

Turnover at Deutsche Börse’s cash markets at 102 billion euros in June
Xetra/FWB: Order book turnover on Xetra, the Frankfurt Stock Exchange and Tradegate stood at E101.8 billion in June (June 2012: E95.8 billion). Of the E101.8 billion, E95.3 billion were attributable to Xetra (June 2012: E89.2 billion). E4.2 billion were attributable to the Frankfurt Stock Exchange (June 2012: E4.6 billion). Order book turnover on Tradegate Exchange* totalled approximately E2.4 billion in June (June 2012: E2.0 billion).

Average daily volume of 10.8 million contracts at Eurex Group in June
In June, the international derivatives exchanges of Eurex Group achieved an average daily volume of 10.8 million contracts (June 2012: 11.0 million). Of those, almost 8.1 million were Eurex Exchange contracts (June 2012: 8.5 million), and 2.7 million contracts (June 2012: 2.5 million) were traded at the U.S.-based International Securities Exchange (ISE). In total, 162.6 million contracts were traded at Eurex Exchange and 54.3 million at ISE.

MGEX Reports Double-Digit Year Over Year Volume Growth
MINNEAPOLIS – MGEX, a Designated Contract Market (DCM) and Derivatives Clearing Organization (DCO), today announces its ninth month in a row of year over year volume growth. Total volume was up 12.3 percent from June 2012 and 40.6 percent from May 2013. Total Exchange volume for June 2013 was reported at 125,703 contracts traded.

ICE Reports Second Quarter Futures ADV up 3%; Buyside CDS Clearing Surpasses $1.5 Trillion
IntercontinentalExchange, a leading operator of global markets and clearing houses, today reported futures volume for June and the second quarter of 2013. ICE’s average daily volume (ADV) for futures and options for June 2013 was 3,465,509 contracts, a decrease of 4% from the prior June. Total volume in June 2013 was 69 million contracts. ADV for the second quarter 2013 was 3,544,688 contracts, an increase of 3% from the prior second quarter.

ISE Reports Business Activity for June 2013
The International Securities Exchange (ISE) today reported an average daily volume of 2.7 million contracts in June 2013. This represents an increase of 9.3% compared to June 2012. Total options volume for the month was 54.3 million contracts. ISE was the second largest U.S. equity options exchange in June with a market share of 16.7%*.

Key figures for SIX Swiss Exchange and Scoach Switzerland: June 2013/H1 2013
In the first half of 2013, a total of 17,817,289 transactions – a daily average of 146,043 – were conducted on SIX Swiss Exchange and Scoach Switzerland. This constitutes a year-on-year increase of 6.4%. There were 16,573,448 trades in the equities including funds + ETPs segment, equating to a rise of 6.5%. The ETF segment also posted strong growth. There were 505,917 transactions in this segment in total, 26.9% more than in the corresponding period last year.

Nordic Growth Market NGM AB: June Turnover Exceeds 3.3 Billion SEK (388 Million Euro) At NGM
Nordic Growth Market NGM generated a total turnover exceeding 3.3 billion SEK (388 million Euro) for June 2013, based on NGM’s three markets; Sweden, Finland and Norway.

Tradeweb Volume Grows In European Fixed Income Markets – Institutional Investors Continue To Seek The Benefits Of Electronic Trading
Tradeweb Markets, the leading global provider of fixed income marketplaces, announced a 34 percent year-on-year increase in trade volume for European government bonds in the first half of 2013, and 31 percent growth for European cash credit volume during the same period.

BME: The Spanish Stock Exchange Traded E58.5 Billion In June, Up 21.5% From May

NASDAQ OMX Nordic and Baltic Trading Statistics June 2013

ETF Market Quality Improved Under ASX Scheme – CMCRC

Hedge Funds & Managed Futures

BNY Mellon receives licence approval for new separately managed accounts business in Hong Kong
BNY Mellon, the global leader in investment management and investment services, has received licence approval from the Securities and Futures Commission (SFC) for its new dedicated Hong Kong-based subsidiary* to establish a separately managed accounts business.

Morgan Stanley Alternative Investment Partners Raises $770 Million for Global Secondary Opportunities Fund II
Morgan Stanley Investment Management (MSIM) today announced that Morgan Stanley Alternative Investment Partners (AIP) raised $770 million in commitments for the Morgan Stanley Global Secondary Opportunities Fund LP II (GSOF II), a fund dedicated to acquiring interests in private equity funds in the secondary market. The capital raised exceeded AIP’s initial $600 million target.

The IRS Is Getting Serious About Cracking Down On Another Cherished Hedge Fund Tax Loophole
Business Insider
Legendary hedge fund manager James Simmons has caught the ire of Wall Street’s friends at the IRS by using a tax cutting strategy known as basket options contracts, Bloomberg reports.

India Urges Resisting Gold as Curbs Fail to Stem Currency Slump
Indian policy makers are urging citizens to resist buying gold and boosting scrutiny of speculative currency trades after import curbs and dollar sales failed to stem the world’s biggest currency loss.

Subscription launch for DIC Asset AG corporate bond

Banks & Brokers

Banks Seek a Détente With CFPB
Big U.S. banks are working behind the scenes to ease tensions with a new federal consumer regulator whose approach to policing the financial sector has triggered industry criticism.

Ken Hitchner to Become President of Goldman Sachs in Asia Pacific Ex-Japan
The Goldman Sachs Group, Inc., announced today that Ken Hitchner will become President of Goldman Sachs in Asia Pacific Ex-Japan, with day-to-day responsibility for all of the firm’s businesses in the region. He will be based in Hong Kong and will work closely with Mark Schwartz, Chairman of Goldman Sachs Asia Pacific, and Masa Mochida, President of Goldman Sachs Japan.

Citigroup pays Fannie Mae $968 million to resolve mortgage claims
Washington Post
Citigroup said Monday that it had agreed to pay mortgage-finance giant Fannie Mae $968 million to resolve claims on 3.7 million home loans that have soured or might go bad.

Vatican Bank managers resign over money-laundering scandal
The Standard-Times
The managers of the Vatican bank resigned on Monday, three days after the Vatican’s bank was hit by a new scandal.

Political interference at RBS could get even worse
Iain Martin – Financial News
This autumn it will be five years since Royal Bank of Scotland had to be rescued by the taxpayer. When the bank almost went down in flames in October 2008, its balance sheet was in excess of £1.9 trillion, a sum bigger than the UK’s gross domestic product.

Clearing & Settlement

OCC Announces Cleared Contract Volume In June Rose 11%
OCC announced today that total cleared contract volume in June reached 367,660,030 contracts, an 11 percent increase from the June 2012 volume of 329,891,797 contracts. OCC’s average daily volume for the month was up 17 percent with 18,383,002 contracts. OCC ended the first half of the year with total cleared contract volume reaching 2,142,294,926 contracts, 2 percent higher than the first half volume of 2012.

ICE Clear Europe Completes Clearing Transition of NYSE Liffe Derivatives Contracts
ICE Clear Europe, a wholly-owned subsidiary of IntercontinentalExchange, and NYSE Liffe, the derivatives division of NYSE Euronext, today announced the completion of the clearing transition for the London-based derivatives market of NYSE Liffe to ICE Clear Europe.

LCH.Clearnet Granted Licence to Extend Interest Rate Swap Clearing Service to Australian Banks
LCH.Clearnet Limited, the multi-national clearing house, today announced that the Australian government has granted an extension to its existing clearing and settlement facility licence in Australia that will enable LCH.Clearnet to offer its market-leading SwapClear OTC interest rate swap clearing service directly to Australian banks.

NYSE Liffe U.S. Announces New Records for mini MSCI Futures

CME Group Trade API Enhancement: Adding ClearPort Allocation ID (AllocID2)

CME Clearing – Performance Bond Requirements: CME Equity Index Outright Margin Change- Effective Tuesday, July 2, 2013

Indexes & Products

Broker-Dealers ETF Up Over 30% This Year
ETF Trends via Yahoo! Finance
A little-known ETF tracking specialized financial-services firms linked to Wall Street is one of the top-performing funds this year with a gain of more than 30%.

Qatar Exchange – QE Al Rayan Islamic Index: Up 180% Since January 2007

Moscow Exchange Indices Weekly Review: June 24-28, 2013


Interactive Data Enhances FutureSource with New Content Sets and Analytics
Interactive Data Corporation, a leading provider of market data solutions to the global commodities and energy industry, today announced the availability of its latest version of FutureSource, designed to deliver cost-effective market data management, analytics and trade execution through a variety of futures commission merchants.

Numerix Names New Managing Director of EMEA Sales Territory
Numerix, the leading provider of cross-asset analytics for derivatives valuations and risk management, today announced the promotion of John Peck to Managing Director of EMEA at Numerix where he will oversee all direct sales and pre-sales efforts – driving the day-to-day initiatives of financial engineering, quantitative research and development teams across the region.


Federal Court in New York Orders Defendant Laurence Dodge, Principal of Madison Dean, Inc., to Pay nearly $400,000 to Settle Forex Fraud Charges
The U.S. Commodity Futures Trading Commission (CFTC) obtained a federal court consent Order of permanent injunction against Laurence Dodge of Fresh Meadows, New York, a principal of Madison Dean, Inc. of Wantagh, New York, requiring Dodge jointly to pay nearly $250,000 in restitution to customers and a $150,000 civil monetary penalty.

EU seeking to settle with banks in Euribor, Libor cases by year-end
Reuters via Yahoo! News
EU regulators are seeking to settle with a group of banks under investigation for suspected rigging of lending benchmarks Euribor and Libor in a procedure which includes lower fines in return for admission of wrongdoing, the EU’s antitrust chief said on Monday.

Ex-JPMorgan Deal Adviser Hannam Fights Fine Over Heritage Tip
Ian Hannam, formerly one of JPMorgan Chase & Co. ’s top merger advisers, was seeking more bidders for one of his clients, Heritage Oil Plc , when he disclosed to an investor that another potential acquirer had made an offer.

Notice of Covered Action – Eric N. Schmickle, Q Wealth Management Inc. – Award Claims Due No Later than September 29, 2013

Notice of Covered Action – Michael Alcocer and Inovatrade, Inc. – Award Claims Due No Later than September 29, 2013

Notice of Covered Action – PMC Strategy, LLC, Michael Hudspeth, and Timothy Bailey – Award Claims Due No Later than September 29, 2013

Notice of Covered Action – National Equity Holdings, Inc., Robert J. Cannone, Thomas B. Breen, Francis Franco – Award Claims Due No Later than September 29, 2013

Environmental & Energy

New Jersey May Join Climate Group Christie Opted Against
New Jersey would rejoin nine U.S. Northeast states in a market to reduce greenhouse gas emissions if it musters enough votes to pass legislation that Governor Chris Christie has vetoed twice.

New Compliance Association Unites California Offset Project Developers
Ecosystem Marketplace
Stemming from the Navigating the American Carbon World conference in 2012, the newly formed Compliance Offset Developers Association (CODA) seeks to unite project developers and to support an effective cap-and-trade program in California. CODA provides a platform for sharing technical knowledge and ideas as they pertain to the Air Resources Board.

Ministers and blue chips unite in call to save EU carbon market
Business Green
The UK has again joined with 11 other countries and businesses across Europe to call on the European Union to urgently approve a temporary fix to its Emissions Trading System (ETS) that could force up the price of carbon.


Thai Bourse Announces Executive Vice President For Market Operation
The Stock Exchange of Thailand (SET) has appointed Chanisa Chutipat as SET Executive Vice President and Head of Market Operation Division, overseeing overall post-trade services, trading operations, clearing house, securities depository, securities registration and provident fund registration, effective from July 1, 2013.

Dalian Commodity Exchange: Preparing For Listing Of Iron Ore Futures
While Dalian Commodity Exchange (DCE) is vigorously pushing forward the approval of the listing of the iron ore futures, on June 27, China Iron and Steel Association (CISA) held the training class of iron ore futures in Dalian with more than 200 attendees from CISA members and the institutions of related industries from home and abroad.

UBS Starts Gold-Vault Service in Singapore Amid Bullion Rout
The leased vault in the Singapore Freeport is available for clients in the city-state and Hong Kong, according to Peter Kok, regional market manager for wealth management in Singapore and Malaysia. While bullion is heading for the first annual drop in 13 years, client interest persists, Kok said.

Loan Practices of China’s Banks Raising Concern
Text message solicitations began arriving on the mobile phones of many of China’s wealthy last month, promising access to lucrative wealth management products with yields far above the government’s benchmark savings rate.

Frontier Markets

Dubai Mercantile Exchange Announces Record Trading Volume In June
DME (Dubai Mercantile Exchange) today announced a record trading volume of 6,978 ADV in June 2013. This is a 9% increase over the previous record of 6,415 ADV in May 2012, 38% higher than June last year and is a 32% increase on last month.

TCW Launches TCW Emerging Markets Multi-Asset Opportunities Fund
Business Wire via Yahoo! Finance
The TCW Group, a global asset management firm, announced today the launch of the TCW Emerging Markets Multi-Asset Opportunities Fund . The fund expands upon TCW’s stro

Goldman Turns Bearish on BRIC Economies
Goldman Sachs says it has ended a recommendation to buy a basket of U.S. stocks with the highest sales exposure to Brazil, Russia, India and China and instead prefers U.S. firms with most exposure to the domestic market – just one more sign that sentiment towards emerging markets is fading fast.

Tel Aviv Stock Exchange Aligns With World Derivatives Markets: Starting 3 July: Weekly Options And Futures On The TA-25

Johannesburg Stock Exchange (JSE) Equity Market Notes 1st Anniversary Of Millennium Exchange


Good School Hunting
Trade Talk – Trading Technologies
Now before the villagers storm the castle with sickle and sword, let me just say I’m a patron of the arts and a strong supporter of a liberal arts education. “Higher” education makes us better people and indirectly makes our world a better place. There is more to a college education than simply job training. Having said that, the cost of education is so prohibitively high that the option of spending four years (or more) “finding oneself” on a university campus is limited to the small percentage of our population who have deep pockets.

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